Subject: SR-NYSE-2023-09
From: Paul Peaden
Affiliation:

Jan. 16, 2024

The good thing I see in this is a concern for managing our resources wisely. We do need to preserve both natural areas and resources to be wisely managed in the future. What appears wise to some will not appear to be wise to all, hence the need for input from many as some may bring up issues unseen that others will not. You can not go strictly by numbers addressing a given issue, but an honest evaluation of consequences of implementing new processes should be taken. What follows are a couple of my concerns. 


It does not seem reasonable to turn over public lands to private companies. It appears that in many respects they are being given complete control such that they could restrict access, use, availability, and could even use such control as a means of extortion, and special treatment to "preferred groups" who support their specific causes whether it has anything to do with the jurisdiction they have been given or not. This is wrong. We end up with groups having control who are not beholden to the public. 



Another problem, not as serious, but related to the first is taken from the text of the document: " The NAC will be prohibited from engaging directly or indirectly in unsustainable activities. These are defined as activities that cause any material adverse impact on the condition of the natural assets under its control, and that extract resources without replenishing them (including, but not limited to, traditional fossil fuel development, mining, unsustainable logging, or perpetuating industrial agriculture). The NAC will be prohibited from using its funds to finance such unsustainable activities." 


I can see "unsustainable" being twisted to either prohibit or allow activities the NAC sees beneficial to its own political persuasions or interests, not being impartial at all! It is also unclear what "without replenishing" really entails. To lock up needed resources to make them totally unavailable is unwise, just as unwise as not providing a means for either recycling or replenishing the resource. I see no provisions for these aspects in the document. Also, I see access being restricted to resources that may end up being essential to our well being by an entity that has no accountability to the general well being of the country, only to some unstated self-serving or political purpose.